MOTION FOR TEMPORARY RESTRAINING ORDER

Pursuant to Section 12, Rule 43 of the Rules of Court, Petitioners

respectfully request that this Honorable Court issue a Temporary Restraining
Order (TRO) to enjoin enforcement of the 15 February 2013 Decision and
31 October 2013 Order, until there is a resolution on this Petition for
Review.

Petitioners are left with no speedy and adequate remedy at law except
the issuance of a TRO. Unless a TRO is issued, the Petitioner is certain to
suffer grave injustice, irreparable injury and damage.

An injury is considered irreparable if there is no standard by which

their amount can be measured with reasonable accuracy, that is, it is not
susceptible of mathematical computation.1

Petitioners and their family would suffer tremendously as a

consequence of their removal. Petitioners should not be made to suffer for
something they did not commit. Accordingly, enforcement of Petitioner’s
dismissal should be restrained to prevent embarrassment, unnecessary
shame, social humiliation and besmirched reputation.

Moreover, the penalty of dismissal would certainly be very harsh and

disproportionate to the alleged infraction committed, considering that
Petitioners were accused of grave misconduct for the first time and there is
even no evidence on the depravity of conduct or conclusiveness of guilt to
planning, preparation and/or perpetration of the purported violation of R.A.
9184.

It is clear that the injury which Petitioners stand to suffer by cannot be

adequately compensated and therefore, there exists an "irreparable injury,"
as defined above which would necessitate the issuance of the TRO sought
for.

1
Philippines Airlines v. NLRC, G.R. No. 120567, March 20, 1998.